Working Lead Safe
U.S. EPA
Renovation, Repair and Painting
The Ohio Department of Health
National Data
Out of 39 states funded by US EPA:
Environmental Protection Agency (EPA)
Ohio has the 5th highest number of housing
units with lead-based paint.
Reports from 19 states funded by CDC:
Centers for Disease Control (CDC)
Ohio has the 2nd highest percentage of
children under age 6 with EBL (elevated
blood lead).
Health risks associated
with lead poisoning
At Lower Levels
Reduced IQ
Learning Disabilities
Attention deficit disorders
Behavioral Problems
At Higher Levels
Anemia
Impaired hearing
Kidney Damage
Death
Blood Lead
(ug Pb/dl)
CHILDREN
150
ADULTS
Death
100
Encephalopathy
Nephropathy
Frank Anemia
Encephalopathy
Frank Anemia
Decreased Longevity
Colic
50
Hemoglobin Synthesis
Vitamin D Metabolism
Nerve Conduction Velocity
40
30
Systolic Blood Pressure (MEN)
Hearing Acuity
20
Erythrocyte Protoporphyrin
Vitamin D Metabolism(?)
DEVELOPMENTAL TOXICITY
IQ
HEARING
GROWTH
Hemoglobin Synthesis
Peripheral Neuropathies
Infertility (MEN)
Nephropathy
Erythrocyte Protoporphyrin
(Women)
10
Hypertension (?)
Transplacental Transfer
- Low birth weight
- Miscarriages, Stillbirth
- Premature birth
Lead Exposure and IQ
• Each 2.5 ug/dL
increase in blood
lead level yields
a one point
decrease in IQ.
Lead Poisoning Facts
•Lead in paint intended for residential use was outlawed in 1978.
•80-90% of lead poisoning cases are caused by the deterioration of
old paint in older residences
•Ingestion of a lead paint chip can result in very high blood lead levels
•Degradation of the paint into dust particles is the primary source of
childhood lead poisoning
Small children are at high risk because:
.
Small children crawl on the floor, touch a lot of things and
frequently put their hands in their mouths.
Small children are developing rapidly; small disruptions
become big problems during growth
U.S. EPA
Lead-Based Paint
Renovation, Repair, and Painting
Rule
RRP
The rule was designed to
prevent the introduction of
new lead hazard created by a
renovation, not to address
existing lead hazards
Effective Dates

–
–

–

–
–

–

–
–
–
–
–
June 2008:
States and tribes may begin applying for authorization
Some restrictions apply to unaccredited training programs
December 2008:
“Renovate Right” brochure must be used for 406(b)
April 2009:
EPA begins administering program in unauthorized states
Training providers may begin applying for accreditation
October 2009:
Renovation firms may begin applying for certification
April 2010:
Training providers must be accredited
Renovation firms must be certified
Renovators and dust sampling technicians must be
certified
Workers must be trained
Work practices must be followed
2008
• June 23, 2008 –
– States may seek authorization to administer and
enforce
• June 23, 2008 –
– Training programs can not offer or claim to
provide training for EPA certification as a
renovator or a dust sampling technician with out
accreditation from the EPA
• December 22, 2008 –
– Renovate Right : Important Lead Hazard
Information for Families, Child Care Providers and
Schools must be used exclusively
2009
• April, 2009 –
• EPA begins administering the program in
unauthorized states (Ohio)
• April 22, 2009 –
• Training programs may apply for accreditation to
provide training for renovators and dust sampling
technician
• October 22, 2009
– Firms may apply for certification to the EPA
2010
• April 22, 2010
– Training providers must be accredited
– Renovation firms must be certified
– Renovators and dust sampling technicians
must be certified
– Workers must be trained
– Work practices must be followed
Who is covered under the rule?
All persons who do
renovations for
compensation,
including renovation
contractors,
maintenance workers,
painters and other
specialty trades in
target housing and
child-occupied
facilities.
Applicability
•
Target Housing – Any housing constructed prior to 1978
•
Child-Occupied Facilities – A building, or a portion of a building,
constructed prior to 1978 where a child
under 6 years of age visits;
– Maybe located in targeted housing or
commercial buildings (day care centers,
preschools and kindergarten classrooms
Firm Certification
• Firms must pay a $300 fee and apply for
certification to perform renovations or dust
sampling.
• Certifications are good for 5 years.
• Certification allows the firm to perform
renovations in any non-authorized state or
Indian tribal area.
Responsibilities of the Certified
Firm
• All persons performing renovation activities are
certified renovators or have received on-the-jobtraining by a certified renovator;
• A certified renovator is assigned to each renovation
performed by the firm; and
• All renovations are performed in accordance with
applicable work practice standards.
Certified Renovator
• To become a certified renovator a person must
successfully complete a training course offered by a
training provider accredited by EPA or by an
authorized state or tribal program.
• Course completion certificate serves as proof of
certification.
• Training providers to notify EPA of names of trained
renovators.
• Certification allows the renovator to perform
renovations in any non-authorized state or Indian
tribal area.
Certified Renovator
• To maintain certification, refresher course must be
taken within 5 years of the initial course. If the
refresher course is not taken within this time, the
initial course must be re-taken.
• Persons who have a valid abatement supervisor or
worker certification issued by EPA or by an
authorized state (Ohio) or tribe are also deemed to
be certified renovators.
Responsibilities of the
Certified Renovator
• Perform or direct uncertified workers who perform
regulated renovation activities;
• Provide training to uncertified workers on lead-safe
work practices;
• Be present at the work site during key stages of a
renovation, and at other times be available on-site or
by telephone; and
• Be able to use an acceptable test kit to determine
whether lead-based paint is present on components to
be affected by a renovation.
Dust Sampling Technician
• RRP also contains
provisions for the
training and certification
of dust sampling
technicians- clearance
purposes only
• “Clearance Technician”Ohio-specific term
• In Ohio only a licensed
Clearance Technician,
Lead Risk Assessor or
Lead Inspector Can take
dust wipe samples for
laboratory analysis
Interior Renovation Procedures
• Remove or cover all objects
from the work area.
• Close and cover all ducts in
the work area.
• Close or cover all windows
and doors in the work area.
• Cover the floor surface of
the work area with plastic
sheeting.
• Ensure that all personnel,
tools, and other items
including waste are free of
dust and debris when leaving
the work area.
Renovations Outside
• Close all doors and
windows within 20
feet of the
renovation.
• Cover the ground
with plastic sheeting
extending out from
the edge of the
structure a
sufficient distance
to collect falling
paint debris.
Waste
• During renovation waste must be contained to prevent
releases of dust and debris.
• At the end of each work day and at the end of the
job, waste must be contained or enclosed to prevent
release of dust and debris and prevent access.
• When the firm transports waste it must be contained
to prevent releases of dust and debris.
Clean-up
• After the renovation has been completed, the firm
must clean the work area until no visible dust, debris
or residue remains.
• Pick up all paint chips and debris.
• Remove all protective sheeting.
Clean-up
Clean all objects and surfaces in
and around the work area.
– Clean walls with a HEPAequipped vacuum or with a
damp cloth.
– Vacuum all remaining surfaces
and objects in the work area,
including furniture and
fixtures, with a HEPAequipped vacuum.
– Wipe all remaining surfaces
and objects in the work area
with a damp cloth.
– Mop uncarpeted floors.
Cleaning Verification
• The EPA has developed a unique method for post
renovation cleaning verification.
• Must be conducted by certified renovator.
• Relies on the use of Wet and Dry Disposable Cleaning
Cloths.
• Cloths are to compared to a Cleaning Verification
Card developed by EPA.
• Data shows that this approach provides reliable
information on the removal of lead hazards.
• Laboratory dust sampling may alternatively be used to
verify cleaning.
Cleaning Verification
• Wipe the windowsill and/or uncarpeted floor with wet
cleaning cloth.
• If the cloth does not match the verification card, reclean that windowsill and/or uncarpeted floor and
then re-wipe with a wet cleaning cloth.
• If this cloth does not match the cleaning verification
card, re-clean that windowsill and/or uncarpeted
floor again, then wipe with a dry cleaning cloth until it
matches the verification card.
Verification Card
Verification Card
Record Keeping
• Firms must retain documentation necessary to
demonstrate compliance with rule for 3 years
following a renovation.
• Copy of the certified renovator’s training certificate.
• A signed and dated form that describes:
– Worker training,
– Sign posting,
– Work area containment,
– Waste handling,
– Cleaning, and.
– Post-renovation cleaning verification.
Ohio and the RRP Rule
Where do we go from here?
• Must seek delegation of both RRP and
Pre Renovation Education (PRE)
• Modifications to existing Lead Law
– Legislative support needed
– Interest group support a challenge
– Ohio political climate
Questions?
Ohio Department of Health
Lead Poisoning Prevention Program
246 North High Street
Columbus, Ohio
1-877-668-5323
www.odh.ohio.gov
lead@odh.ohio.gov
Program Staff:
Dave Holston, Section Chief
Chris Mizek, Sanitarian II
Matt Young, Sanitarian II
Sandra Foster, Customer Service Assistant II